On May 20, 2025, NERC issued a Level 3 Alert, its highest-level alert, requiring all Generator Owners (GOs) with Inverter-Based Resources (IBRs) — including solar, wind, battery, and fuel cell facilities — to respond to critical concerns about inaccurate modeling and performance deficiencies that have contributed to widespread grid disturbances.
Key Actions for GOs:
- Obtain and retain model validation and benchmark reports for both inverters and power plant controllers
- Ensure the as-built configuration of your facility reflects the dynamic model submitted during interconnection
- Establish a robust model management process to track field and model changes and ensure IBR data remains current
- Strengthen change management protocols, particularly around firmware updates
Immediate Requirements — Response Due August 18, 2025:
If you're a registered GO with IBRs, you must:
- Submit your response in the NERC Alert System by August 18, 2025
- Address questions related to current modeling, validation, and change management practices
- Develop a credible implementation plan, even if full compliance extends into 2026 or 2027
How EPE Can Help
We offer comprehensive support to help you navigate this critical compliance requirement:
- Assist with preparing and submitting your response (Questions 9–13)
- Develop a credible, actionable implementation plan in line with NERC’s expectations
- Provide full technical and management support across the entire project lifecycle—ensuring your modeling efforts align with the key actions outlined in the Alert
Looking Ahead
This Alert not only covers the responsibilities of GOs but also emphasizes the essential actions for Transmission Owners (TOs), Transmission Planners (TPs), and Planning Coordinators (PCs).
As a result, ISOs and RTOs — such as ERCOT, PJM, MISO, and SPP — are expected to adopt stricter modeling requirements for resource entities moving forward.
IBR developers and operators should anticipate increased modeling scrutiny during both interconnection and ongoing operations regardless of the regions.
Working with modeling experts like EPE ensures you stay ahead —avoiding costly delays and penalties while maintaining compliance throughout your asset’s lifecycle.
We’re here to support you every step of the way. Contact our team of experts using the form below.
To learn more about how utilities should respond to the NERC Level 3 Alert—including modeling, validation, and performance guidance—read our companion article here.
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